1.    BUSINESS CHALLENGE

In 1993, following an enforcement action by a provincial environment ministry, a major media print and media organization retained ÉEM to assist in the design and development of a corporate environmental strategy, which included policy, procedures, training and a compliance audit program, covering 20 plants across Canada and the US.  The organization wanted the strategy to become operational on an ongoing basis, to provide risk mitigation and ongoing assurance, and it wanted it to be managed externally.


2.    APPROACH AND STRATEGY

We first surveyed the organization's environmental risks through a 2-day, closed-door meeting with facility managers.  Recognizing that work was needed to correct some situations before a more formal compliance assessment would be appropriate, we then provided regulatory training and management support tools, such as management system documents and operational control procedures to address the significant environmental risks.  Beginning the following year, an audit program was drawn up which featured:

a.    A three-year audit plan covering all facilities, ranked according to risk and findings from previous audits.  The plan was issued at the beginning of each calendar year;
b.    A team of qualified external auditors, geographically located to minimize travel expenses.


3.    SOLUTION

ÉEM conducted the compliance audits, and generated reports on findings related to federal, provincial and municipal legal requirements specific to each of the jurisdictions in which the plants were located.  The audit reports included an assessment of the environmental management practices in place at each facility, noting deficiencies and areas for improvement.  The findings were subsequently turned over to the facility managers and the corporate office for corrective and preventive action.  


4.    RESULTS

The initial audit program described above has grown to cover more than 40 plants across North America, as the organization continues to grow.  Based on 13 years of results, the corporation still believes that this expertise is best provided by an external resource and ÉEM's proposals have withstood competitive evaluations.  The service package which we provide has also evolved to include provision of notices of regulatory changes (through the NIMONIK^TM service), the development and tracking of performance indicators, assistance with initiatives such as the Carbon Disclosure Project and quarterly reporting on the environment to upper management.